The Florida Bar Attorney/Consumer Assistance Program (ACAP)

651 East Jefferson Street Tallahassee, Florida 32399-2300

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In the Matter of: )) Supreme Court No(s): )

WILLIAM B. SHEPRO ) Bar Number 41297 ) )Kevin James Wilcox ) Bar Number 904457 ) Respondents )

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NOTICE OF FILING ATTORNEY DISCIPLINARY COMPLAINT

TO: RESPONDENTS:

William Shepro, Legal Counsel and President ofof Altisource1 Portfolio Solutions S.A. And for888-255-1791Western Progressive2 – Arizona, Premium Title Services Inc.,2002 Summit Blvd, suite 600 Altanta, Ga 30319 www.altisource.com/

Keven J. WilcoxGeneral Counsel Altisource Portfolio Solutions S.A. Western Progressive – Arizona, Premium Title Services Inc.,2002 Summit Blvd, suite 600 Atlanta, Ga 30319 866-960-8299

1 http://www.marketwatch.com/story/altisource-investigation-initiated-by-former-louisiana-attorney-general-kahn-swick-foti-llc-investigates-altisource-portfolio-solutions-sa-following-disclosure-of-department-of-financial-services-2014-08-10

2 Western Progressive, Premium Title Services Inc.,Altisource's wholly owned trustee subsidiaries, processes residential non-judicial foreclosures in California, Nevada and Arizona. Western Progressive-Arizona, Inc. 1150 E. University Drive Tempe, AZ 85281. Phone: 866-960-8299 · stephanie.spurlock@altisource.com

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PLEASE TAKE NOTICE that on the _________ day of June, 2014, I filed with the Clerk of the The Florida Bar Attorney/Consumer Assistance Program (ACAP) 651 East Jefferson Street Tallahassee, Florida 32399-2300 the attached Attorney Disciplinary Complaint

Christopher Stoller

P.O. Box 60645 Chicago, Illinois 60660

312-834-9717

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The Florida Bar Attorney/Consumer Assistance Program (ACAP)

651 East Jefferson Street Tallahassee, Florida 32399-2300

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In the Matter of: )) Supreme Court No(s): )

WILLIAM B. SHEPRO ) Bar Number 41297 ) )Kevin James Wilcox ) Bar Number 904457 ) )

)Respondents )

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ATTORNEY MISCONDUCT COMPLAINT AGAINST

WILLIAM B. SHEPRO AND KEVIN JAMES WILCOX

The Respondent William B. Shepro is charged with the Florida Rules of Professional

Conduct Rule 5.5 unlawful practice of law3 William Shepro who serves as

President and legal counsel for ALTISOURCE PROFOLIO

SOLUTIONS S.A /Western Progressive Arizona Inc.,

3 2012 Florida Statutes 454.23 Penalties.—Any person not licensed or otherwise authorized to practice law in this state who practices law in this state or holds himself or herself out to the public as qualified to practice law in this state, or who willfully pretends to be, or willfully takes or uses any name, title, addition, or description implying that he or she is qualified, or recognized by law as qualified, to practice law in this state, commits a felony of the third degree, punishable as provided in s. 775.082, s. 775.083, or s. 775.084.

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Western Progressive LLC.,Premium Title Services Inc.,

unlawfully holds himself out to be an attorney and acts

as legal counsel and for Altisourse4 Portfolio Solutions S.A. And for

Western Progressive5 – Arizona, Inc., and Premium Title

Services Inc.

Keven J. Wilcox Esq., who also serves as legal counsel for ALTISOURCE

PROFOLIO SOLUTIONS S.A /Western Progressive Arizona Inc., Western Progressive

LLC., and Premium Title Services Inc., is charged with violating Florida Rules of professional

conduct Rule(s) 4.1, 4.3, 4.4, 5.1, 5.2, 5,3, 5.5, 8.1, 8.4 and 8.6 et al., in conducting the

unlawful residential non-judicial foreclosures in Arizona which is clearly evidenced in

the complaint at bar.

The Florida Bar Attorney/Consumer Assistance Program (ACAP) was established

by the Florida is Supreme Court to deal with issues of professional misconduct of attorneys. The

serious allegations of professional misconduct that the Complainant has raised regarding the

Respondents are issues that are not before any court. The issues of professional misconduct

raised by this Attorney Disciplinary complaint are issues that the The Florida Bar

Attorney/Consumer Assistance Program (ACAP) is solely empowered to act upon under the

Florida Rules of Professional Misconduct and NOT any State Court Judge.

4 http://www.marketwatch.com/story/altisource-investigation-initiated-by-former-louisiana-attorney-general-kahn-swick-foti-llc-investigates-altisource-portfolio-solutions-sa-following-disclosure-of-department-of-financial-services-2014-08-10

5 Western Progressive, Premium Title Services Inc. Altisource's wholly owned trustee subsidiary, processes residential non-judicial foreclosures in California, Nevada and Arizona. Western Progressive-Arizona, Inc. 1150 E. University Drive Tempe, AZ 85281. Phone: 866-960-8299 · stephanie.spurlock@altisource.com

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PARTIES

Respondents

WILLIAM B. SHEPRO Bar Number 41297 Kevin James Wilcox Bar Number 904457

Complainant

Christopher Stoller 6045 W. Grand Ave Apt 414

Chicago, Illinois 60639 312-834-9717

BACKGROUND

Christopher Stoller purchased a piece of property in Scottsdale Arizona known as 28437

N. 112th Way Scottsdale, Az 85262-4725 Philip Stone quit claimed his interest to Christopher

Stoller Pension and Profit Sharing Plan Limited (CSPPSP) on September 19, 2008 (Exhibit

1), recorded in the Maricopa County Recorders Office 2008-0815422 on 09/22/08. The

successor trustee was divested of its power of sale after 09/22/08.

On September 19, 2008, Philip Stone transferred and conveys to CSPPSP a Bahamas

Corporation, and/or Christopher Stoller and/or Leo Stoller (collectively, Assignees), under the

Law of Assignments of Causes of Action(Exhibit 2), insofar as permitted by law, forever, any

and all causes of action, remedies, or claims, now or in the future, that Assignor CSPPSP have

against any party, not limited to financial institution, contractors, builders, and their employees,

affiliates, successors and assigns, et al., as well as the right to prosecute such causes of action in

the name of Assignor or Assignees or any of them , and the right to settle or otherwise resolve

such causes of action as Assignees sees fit, regarding the following real property in Maricopa

County, State of Arizona:

Lot 3, Pinnacle Foothills, according to Book 398 of Maps, Page 50, and Affidavit of Correction recorded in Document No. 96-0145582, records of Maricopa County, Arizona.Assessor's Parcel Number: 216-74-044

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Commonly known as: 28437 N. 112th Way, Scottsdale, Az 85262.

Notice(s) of Liz Pendens was filed by the complainant, Christopher Stoller on the subject real estate on 12/29/2008 2008-1090943 with the Maricopa Counter Recorders Office and again another Lis Pendens was filed on 12/02/2013 2013-1025435.

Philip B. Stone, as of 7/23/2014 does not owe a delinquency payment of of

$197,142.49. Nor does Philip B. Stone, as of July 25, 2014 owe unpaid principle balance of

$646,683.87,plus interest from 02/01/2008. As well known to the Respondents, all of these

debts were discharged in Philip B. Stone's Bankruptcy see Exhibit 3, yet the Respondents are

still attempting to collect on these said debts in violation of the Florida Rules of Professional

Conduct and in clear violation of the Federal Fair Debt Collection Act.

Philip B. Stone's promissory note secured by a Deed of trust and the adjustable rate note

together with the deed of trust securing same was canceled as a result of the United States

Bankruptcy Case 10-11558-17, District of New Mexico and the debt discharge, July 19, 2010.

(Exhibit 3).

Complainant filed a full Release and Full Re-conveyance of said Deed of Trust and all

other debts in connection with same, including the Adjustable Rate Note secured by the Deed of

Trust was filed with the Maricopa County Recorder Office 2014-0512240 08/04/14. (Exhibit 4)

Notwithstanding the fact that Philip B. Stone was not the owner of record on July 23,

2014 and did not owe any monies including the said delinquency payment of of $197,142.49.

Nor does Philip B. Stone, as of July 25, 2014 owe unpaid principle balance of $646,683.87,plus

interest from 02/01/2008. Stone's debts were all discharged in bankruptcy Exhibit 3.

The respondents William B. Shepro and Keven J. Wilcox caused to be file an unlawful

Notice of Trustee's Sale under oath and caused the fraudulent document Group Exhibit 5 to be

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recorded in the Maricopa County Recorder's Office Document number Number 20140480249.

Complainant served a Objection to the Respondents via email and certified mail on 7-23-

14 the fraudulent Notice of trustee Sale (Group Exhibit 5) filed by the respondents, with the

Maricopa County Recorder's Office on 7/23/2014 Document no. 20140480249 announcing that

the Complainant's property known as 28437 N. 112th Way, Scottsdale, Az 85262-4725 will be

sold “at public auction to the highest bidder. At the main entrance of the Superior Court Building

201 W. Jefferson, Phoenix Az 85003, on 11/12/2014 at 12:30PM of said day.” at ¶ 1, Document

20140480249.

The said Notice of Trustee's Sale (Group Exhibit 5) filed by the Respondent's represents a clear fraud on the Maricopa County Recorder’s Office, a clear fraud on the Florida Bar Associations Rules of Professional Conduct 8.4 and a clear fraud on the Complainant for the following reasons:

The Trustee in the Notice of Trustee Sale document (Group Exhibit 5) has no power and/or authority to convey the deed of trust dated 05/02/2006 because Philip Stone quit claimed his interest to Christopher Stoller Pension and Profit Sharing Plan Limited (CSPPSP) on September 19, 2008, recorded in the Maricopa County Recorders Office 2008-0815422 on 09/22/08 (Exhibit 1) as well known to the Respondents.

The successor trustee was divested of its power of sale after 09/22/08. On September 19, 2008, Philip Stone transfers and conveys to CSPPSP a Bahamas Corporation, and/or Christopher Stoller and/or Leo Stoller (collectively, Assignees), under the Law of Assignments of Causes of Action (Exhibit 2), insofar as permitted by law, forever, any and all causes of action, remedies, or claims, now or in the future, that Assignor CSPPSP have against any party, not limited to financial institution, contractors, builders, and their employees, affiliates, successors and assigns, et al., as well as the right to prosecute such causes of action in the name of Assignor or Assignees or any of them , and the right to settle or otherwise resolve such causes of action as Assignees sees fit, regarding the following real property in Maricopa County, State of Arizona:

Lot 3, Pinnacle Foothills, according to Book 398 of Maps, Page 50, and Affidavit of Correction recorded in Document No. 96-0145582, records of Maricopa County, Arizona.Assessor's Parcel Number: 216-74-044

Commonly known as: 28437 N. 112th Way, Scottsdale, Az 85262.

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The former Trustee, Reconstruct Co NA, was not registered as a loan servicer, broker with the Arizona Department of Financial Institutions as of September 9, 2011 and pursuant to their Notice of Trustee Sale Arizona recorded in the Maricopa Recorders Office 20110752511 on 09/09/2011 (Exhibit 7) and lacked the authority to transact business within the State of Arizona. The Trustee Sale Arizona was void ab initio and canceled by the Trustee.

The complainant's shell entities,ALTISOURCE PROFOLIO SOLUTIONS S.A /Western Progressive Arizona Inc., Western Progressive LLC.,, herein after referred to as(WPAI) (Substitution Trustee) are not registered with the Arizona Department of Financial Institutions and are not licensed as a broker or servicer of mortgages as of the date July 23, 2014 that the respondents filed with the Maricopa Recorders Office its Substitution of Trustee ( 20140433956). Group Exhibit 5

Christiana Trust, a division of Wilmington Savings Fund Society, Trustee of ARLP Trust 3, s not registered with the Arizona Department of financial institutions and is not licensed as a broker or servicer of mortgages as of the date July 02, 2014. Nor are they registered with the Arizona Corporation Division and they do not have a corporation certificate of authority to transact business within the State of Arizona.

On July 23, 2014 the Respondents filed their Notice of Trustee Sale and Debt Validation Notice, Statement of breach and non performance, and these documents (Group Exhibit 5) were fraudulently recorded with the Maricopa Recorders Offices on July 23, 2014 20140480249.

As well known to the Respondents their successor Trustee WPAI does not qualify as a Trustee of the deed of Trust in the Trustees capacity as an escrow agent as required by A.R.S. § 33-803 (A)(6) according to the Arizona Department of Financial Institutions. WAPI is not a registered Trustee, they have no license.

As well known to the Respondents the statement of breach or non performance ( Group Exhibit 5)falsely claiming that Philip Stone is in “foreclosure because he is delinquent in payments” is a false and misleading statement, because Philip Stone debts have been discharged in Bankruptcy Case No. 10-11558-17 District of New Mexico. The Debt discharge date was July 19, 2010. (Exhibit 3)

As well known to the Respondents the beneficiary or substitute Trustee lacks the authority under the Release and Full conveyance of the Trustee Deed (Exhibit 4) and the cancellation of all of debts, including the adjustable rate note, secured by the Deed of Trust and the Title of the Subject Property being in the name of CSPPHP and cannot not be sold under the conveyance of the Deed of Trust.

As well known to the Complainants pursuant to the Substitution of Trustee (Group Exhibit 5) dated June 9th, 2014 Recorders Number 20140433956, Mel-Ling Mitchell, Contact Management Coordinator, is not an Officer of Ocwen Loan Servicing LLC and is a unauthorized “robo” signer. This is further evidence of the respondents clear fraud on the Maricopa County Recorders Office.

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As well known to the respondents the previous trustee (Exhibit 7) BAC Home Loans Servicing, LP., (BAC) the successor to Countrywide Bank Na, was not registered with the Arizona Corporation Division, was not registered as a Limited Liability Partnership as of April 9, 2009. BAC was not registered with the Arizona Department of Financial Institutions. BAC had no authority to convey any assignment to RECONSTRUCT COMPANY, N.A. or Ocwen Loan Servicing LLC.

On June 3rd, 2014, the Maricopa Country Recorders Office recorded a fraudulent assignment “The record beneficial interest under said Deed of Trust as a result of the last (fraudulent) recorded assignment thereof is Christiana Trust, A Division of Wilmington Savings Fund Society FSB, not in its individual capacity but as Trustee of ARLP Trust 3, by an unlawful instrument Recorded on June 3, 2014, in Maricopa County Records at Recorder's No. 14-360515 c/o Ocwen Loan Servicing LLC 5720 Premier Park Dr West Palm Beach Fl 33407.”

A well known to the Respondents a representative of Ocwen Loan Servicing LLC, who claimed to be an agent, Chirag Patel, on March 26, 20146, informed Christopher Stoller, that he was required to have insurance for his property pursuant to a residential mortgage and since Christopher Stoller has refused to provide a copy of the insurance, Ocwen was placing insurance on the subject property and would be charging $3,000 annually, for a home owners insurance policy that would generally cost about $300.00 per year.

Chirag Patel confirmed in a telephonic conversation Thursday, August 21, 2014. Chiraag Patel confirmed that the Notice of Trustee dated July 23, 2014 and recorded at the Maricopa County Recorder's Office document Number 20140480249 was a fraud and violated the Fare Debt Collection Act by attempting to collect a debt of Philip B. Stone that was discharged in a New Mexico Bankruptcy proceeding. Chirag Patel stated that Ocwen is aware of the Deed of  Re-Conveyance that they received by certified mail, that Ocwen has no lawful interest in the property known as 28437 N. 112th Way Scottsdale, Arizona 85262 and Ocwen Loan and/or its agent Western Progressive-Arizona, Inc., will immediately forward Notice to: 28437 N. 112th Way Scottsdale, Arizona 85262 that the Notice of Trustee's Sale for November 12, 2014 (Exhibit Group Exhibit 5) is permanently canceled. See a true and correct copy of the email marked as Exhibit 8 (email confirmation)

Notwithstanding,the Respondents knowingly and willfully are continuing to unlawfully foreclose (Group Exhibit 5) on the Complainant's property on November 12, 20147

Respondents are well aware that they are not not entitled to enforce the said note or mortgage against Philip Stone, which has been discharged (Exhibit 3) A Released with a full Re-conveyance of the Deed Trust and Cancellation of the Promissory Note and the Adjustable Rate

6 Ocwen Loan Servicing had no authority to place an home owners insurance policy on the subject on March 26, 2004. Christopher Stoller that this was done primarily for the Respondents to receive a “kickbacks” in the form of commissions from the insurance company from whom policies were obtained and placed, which caused the rates and the amount of coverage to be excessive in violation of the law.

7 It is urgent that the The Florida Bar Attorney/Consumer Assistance Program (ACAP) immediately serve upon the respondents a copy of the Complainant complaint and to allow the complaint to file its reply to the Respondents' answer.

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Note securing the Deed of Trust has been filed and recorded with the Maricopa County Recorder Office 2014-0512240 08/04/14. (Exhibit 4) as well known to the Respondents.

The Respondents are in violation of the Fair Debt Collection Practices Act and the Federal Fair Debt Collection Practices Act by attempting to collect on a debt from Philip B. Stone that is not owed that in an of itself is a violation of the Florida Rules of Professional Conduct. The debt has been discharged Exhibit 3.

In Respondents fraudulent Substitution of Trustee Document (Group Exhibit 5) Recording Requested by the sham title company, Premium Title Agency, Inc., filed in the Maricopa County Recorder's office on July 2, 2014 20140433956, states that “The successor trustee (Western Progressive -Arizona, Inc.) appointed herein qualifies as trustee of the trust Deed in the trustee's capacity as an Insurance Company as required by ARS Section 33-803, Subsection (A)(6). The above is a fraudulent statement as well known to the Respondents. As of August 7, 2014 Western Progressive -Arizona, Inc., was not registered with the Arizona Department of Insurance to do business in Arizona as an Insurance Company according to Ruth Ojeda, an employee with the Arizona Department of Insurance.

The Respondents have been notified by the complainant via email and certified mail correspondence of its objection to the fraudulent Trustee Sale which is marked as Group Exhibit 9. The Respondents have refused and failed to take any remedial action to with draw the fraudulent Notice of Trustee Sale (Group Exhibit 5) as of August 17, 2014.

The Respondents are clearly in violation of the Florida Rules of Professional Conduct Rule(s) 4.1, 4.3, 4.4, 5.1, 5.2, 5,3, 5.5, 8.1, 8.4 and 8.6 et al., in conducting the unlawful residential non-judicial foreclosure marked as Exhibit Group Exhibit 5 in Arizona which is clearly evidenced in this complaint.

WHEREFORE, Complainant prays that the The Florida Bar Attorney/Consumer Assistance Program (ACAP) immediately assign this matter to a hearing, panel, that a date for hearing be immediately set, that the hearing be conducted and that the panel make findings of fact, conclusions of law and a recommendation for such discipline as is warranted by its findings. Further that the Respondents be immediately suspended from the practice of law pending a full hearing on this complaint which contains prima facie and irrefutable evidence of the Respondents Professional Misconduct.

Christopher Stoller P.O. Box 60645

Chicago, Illinois 60660 312-834-9717 CERTIFICATION

Under penalties as provided by law, the undersigned certifies that the statements set forth in this instrument are true and correct, except as to matters therein stated to be on information and belief and as such matters the undersigned certifies as aforesaid that he verily believes the

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same to be true. And if called to testify would testify to same.

____________________________

EXHIBIT 1

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EXHIBIT 2

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EXHIBIT 3

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EXHIBIT 4

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GROUP EXHIBIT 5

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EXHIBIT 6

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EXHIBIT 7

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EXHIBIT 8

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EXHIBIT 9

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